Introduction

In April 2012, Ontario’s Office of the Fairness Commissioner assessed the way the College of Occupational Therapists of Ontario   registers people who apply for a licence to practise in Ontario, to ensure that the registration practices are fair and continue to improve.  

This summary of the assessment includes commendable practices that are under way and recommendations for improvement.

The College of Occupational Therapists of Ontario is subject to Ontario's fair access law, which amended the law about health professions, the Regulated Health Professions Act, 1991 (RHPA). The law spells out the college’s obligation to have transparent, objective, impartial and fair registration methods and requirements.

The Office of the Fairness Commissioner

To encourage accountability under the fair access law, the Office of the Fairness Commissioner (OFC) works with professions’ regulatory bodies to improve the way they register people who apply for professional licences. As a result of the OFC’s work, qualified people, no matter where they were originally trained, will have faster, fairer access to their licence to practise here.

In its work with regulators so far, the OFC has found that they have succeeded in streamlining their registration processes, but they need to do more. For example, regulators need to be more transparent and hold their assessment agencies more accountable for fairness.

To encourage, and hold regulators accountable for, continuous improvement, the OFC assesses their licensing practices in a two-year cycle. This cycle includes recommending improvements where needed and monitoring the bodies’ action plans that address the OFC’s concerns. This approach benefits applicants, the professions and the province.

You can read more about the OFC’s strategy for continuous improvement and its guide for assessments elsewhere on this site.

For more information about this particular assessment, contact the OFC.

Note: The words license, register and certify all refer to authorizing a person to practise a profession.

Commendable Practices

The College of Occupational Therapists of Ontario (COTO) is demonstrating many commendable practices, in the following areas. (These areas correspond to the sections of the assessment guide, and are derived from the fair access legislation.)

Information for Applicants

• The COTO website includes information regarding the ways that applicants can meet the COTO's registration requirements, including requirements that may be satisfied through acceptable alternatives.
• The COTO provides the following policy documents on its website :
  • Education & Fieldwork - Canadian Educated Applicants
  • Education & Fieldwork - Internationally Educated Applicants
  • Academic Equivalency Review
  • Currency - Initial Applicants
  • Currency - Annual Renewal
  • Examinations
  • Good Conduct
  • Language Fluency - Requirement
  • Language Fluency - Exemptions Request
  • Legal Authorization to Work in Canada
  • Insufficient or Inadequate Documentation
  • Labour Mobility Support Agreement
  • Provisional Registration - Request for Deferral of Exam
  • Provisional Registration - Request for Exemption
  • Access to Records
  • Assessment of Qualifications
• Information on the COTO's website is clear, concise and user-friendly. The website enables the user to increase the text size easily, making it easier for visually-impaired users to read.
• The COTO updates information on its website whenever the registration requirements change (due to changes in the COTO's registration regulation, COTO policy, or the services provided by third parties).
• When there are changes to COTO registration practices, the COTO informs the Ministry of Citizenship and Immigration so that it can change the career map for occupational therapists. The ministry is also advised when other changes are made that may affect the accuracy of the content of the career map.
• If third-party organizations want to provide information on their websites about COTO registration practices, the COTO encourages them to provide links to its website, rather than reproduce the information on their own site. This way, the information linked will always be current, consistent and accurate.
• The COTO may contact applicants at several points during the registration process, in order to acknowledge receipt of documents, ask for clarification about an application, or request additional documentation.
• The registration information that the COTO provides for applicants describes its communication processes related to applications, such as how quickly applicants will receive a response to inquiries and how long assessment can be expected to take.

Documentation of Qualifications

• The COTO has a process for:
  • considering and examining alternatives regarding documentation of qualifications
  • considering alternate documentation as proof of language proficiency
  • considering whether required documentation is unobtainable for reasons beyond the applicant's control

Assessment of Qualifications

• The COTO maintains a database of occupational therapy (OT) programs outside Canada that have already been assessed and approved. Programs completed by applicants outside of Canada are compared to that database, to ensure transparency, objectivity, impartiality and fairness in the COTO's verification of programs' equivalency to the approved programs.

Training

• The COTO provides training regularly for both registration staff and registration committee members. Individuals who make registration decisions are also given training for special considerations (such as dealing with acceptable alternatives to required documentation, and accommodation of special needs).

Access to Records

• The COTO website includes the COTO's comprehensive policy on access to records.

Transparency

• All of the COTO's registration policies are available to the public on its website. The information is clear, concise and unambiguous.

Objectivity

• The COTO's Academic Review Tool, which is used to determine the substantial equivalency of OT programs, is based on a comparison of a program's course curriculum to either:
  • an approved Ontario program
  • or
  • an academic qualification considered equivalent by the registration committee in accordance with the document, Essential Competencies for Occupational Therapists in Canada. This document was developed by the Association of Canadian Occupational Therapy Regulatory Organizations (ACOTRO).

Impartiality

• The COTO has a formal agreement with the Canadian Association of Occupational Therapists (CAOT) and with World Education Services that outlines their obligations to be fair and transparent in their services for the COTO.

Fairness

• The COTO's registration requirements do not unjustifiably limit any group, particularly internationally educated occupational therapists. The COTO's regulation enables applicants not trained in Canada to meet registration requirements in many ways, including through a refresher program.

Recommendations

The OFC recommends improvements in the following areas. (These areas correspond to the sections of the assessment guide, and are derived from the fair access legislation. Recommendations marked "Required" correspond to the practices regulators must demonstrate in order to meet the specific duties in the legislation. Recommendations marked "Good" correspond to the practices the OFC encourages a regulatory body to adopt in order to meet the general duty to provide registration practices that are transparent, objective, impartial and fair.)

Information for Applicants	Status
Make the following changes to the COTO website:
Add a registration application form for applicants whose first language is French. [Good]*	April 2012
Provide a link to the CAOT's fee schedule on its website, to ensure that applicants are aware of the cost associated with reviewing the results of the CAOT certification exam. [Required]	November 2012
Internal "Review"
Ensure that timelines for the COTO's internal review process are made clearer and are included in the COTO's registration materials. [Good]	November 2012
Training
Include anti-discrimination training in the COTO's sensitivity training program. [Good]	May 2013

* The COTO implemented all recommendations marked with an asterisk before the OFC completed its assessment. The OFC commends the COTO for such prompt action.

Blank = Implementation is in progress.
= Recommendation is implemented.
Acceptable alternative = Regulator implements acceptable alternative to this recommendation.